                                 Attachment E

                          Consultation Questionnaire
                                       
"Certification of Pesticide Applicators" (OMB Control No. 2070-0029) 
"Pesticides; Certification of Pesticide Applicators; Final Rule [RIN 2070-AJ20]" (OMB Control No. 2070-0196)


Background

A Federal Register Notice published on 06/30/2021 (86 FR 34745) provides for public comment a batch information collection request (ICR) intended to cover all paperwork burdens associated with implementing the Certification of Pesticide Applicators (CPA) Regulations at 40 CFR 171. OMB Control No. 2070-0029 addresses the burden associated with the CPA rule prior to 2017. OMB Control No. 2070-0196 addresses the incremental increase in burden associated with the 2017 CPA Rule revision. EPA intends to merge these two ICRs into one consolidated ICR for the CPA regulations. Below are a set of questions in order to help the Agency refine its estimates as needed. 

Consultation Questions:

 Publicly Available Data
        
 Is any of the information you are required to report for the Certification of Pesticide Applicator regulation in 40 CFR 171 available from a public source, or already collected by an office other than the Office of Pesticide Programs at EPA or by another agency?  
 If yes, where can you find the data? (Is that data a true duplication or a repetition of only certain data elements?)
Other sources of information would not hold the same information nor the detail of information that is reported into CPARD.  No other office requires this information.  Some certification/licensing information is on our website, but nor in great detail nor easily accessed.
        
   Frequency of Collection
        
 If the Agency were to collect the information less frequently, would it produce the same outcome?  
We could see some benefit for a report requiring a three-year average, once every three years  for those categories reported into CPARD.  We do know that the CPARD reporting is used to calculate grant funds for our certification portion of the PPG, but we think the impact would be minimal with a 3-year average report instead of an annual report.
        
 Clarity of Instructions
        
     The ICRs are intended to require that respondents provide certain data so that the Agency can utilize them.
     
 Do you know that you are required to report information?
YES  -  we are aware of the annual CPARD Reporting.  
     
 Based on the instructions you are given for reporting information (regulations, PR Notices, etc.), is it clear what you are required to do and how to submit information?  
 If not, what suggestions do you have to make the instructions clearer?  
YES  -  instructions are generally clear if there are questions about the report, we can generally contact C&T Program staff for our answers.
        
 Is it difficult to submit information in ways that are clear, logical and easy to complete?
There is no real difficulty in the reporting, format is clear an easy to follow.  
        
 Are there forms associated with this process?  
 If so, do you use them? Are they clear, logical, and easy to complete?
If CPARD and CDX are considered forms  -  yes.  They are generally easy to follow.  

 Electronic Reporting and Recordkeeping
        
     The Government Paperwork Elimination Act requires agencies make available to the public electronic reporting alternatives to paper-based submissions by 2003, unless there is a strong reason for not doing so. One such reason is that, at the present time, the Agency is unable to ensure the security of CBI that might be transmitted over the Internet.
     
 Do you keep and/or report information/records electronically?  
 If yes, in what format(s)? 
CDX and CPARD are all submitted electronically.  There are no printed versions of these reports. 
        
 What benefits do electronic submission of information bring you in terms of burden reduction or greater efficiency in terms of compiling the information?  
Electronic submission is easier for the federal partners; however, it is cumbersome for state partners in regard to CDX.  CDX does not allow the import or export of data in an easy manner.  CDX should be easily downloaded into an Excel format.  CPARD is easy to navigate and report electronically for States.  
        
 Burden and Costs
        
 Are EPA's estimated labor wage rates accurate? 
No  -  not in relation to most State employee wages who are doing the reporting.   
        
 The Agency assumes there is no capital cost associated with this activity. A capital cost is a one-time set up cost of a project after which there will only be recurring operational or running costs. 
 Is this a correct assumption?   
 If not, what are your capital costs? 
There are no capital costs involved for States.
        
 Bearing in mind that the burden and cost estimates are associated only with the paperwork involved with these ICRs (e.g., the ICR does not include estimated burden hours and costs for conducting studies), are the estimated burden hours and cost estimates accurate?
Yes   
        
 If you provide burden and cost estimates that are substantially different from EPA's estimates, please provide an explanation of how you arrived at your estimates.
        
 Are there other costs that should be accounted for that EPA may have been missed?  
Unknown
                                       
